Five Key Health Policy Stories and Trends for 2025
As we begin a new year, it is also time to take stock of the year that has just passed. By any measure, 2025 was tumultuous. The inauguration of the second Trump Administration ushered in a year of unprecedented change not only at the Department of Health and Human Services (HHS) but also across the broader healthcare landscape. Some of what we experienced in 2025 was entirely new, but in other cases, existing trends and policies gained traction and were amplified.
To add to the mountain of end-of-the-year lists, here are my Five Key Health Policy Stories and Trends for 2025. These were selected with an eye toward what most affected practicing physicians, nurses, and other qualified healthcare professionals this past year.
#1: CY 2026 Medicare PFS is a Win for Primary Care
While 2025 was a challenging year for primary care in many ways, the CY 2026 Medicare Physician Fee Schedule (PFS) Final Rule, issued on October 31, 2025, included many policies that increased reimbursement for primary care, particularly for those practicing in independent office settings. In a statement on the final rule, the American College of Physicians wrote that it will “…better support primary and comprehensive care.”
Key Primary Care Wins in the CY 2026 Medicare PFS
Primary care was essentially exempt from the 2.5% across-the-board cut on work RVUs that CMS referred to as an efficiency adjustment.
Many primary care practitioners benefited from the higher conversion factor update, which will be implemented for the first time in 2026 (0.75% versus 0.25%). They are eligible for the higher update because they participated in Accountable Care Organizations. There are fewer opportunities for specialists to receive the higher 0.75% update.
Other policies in the final rule that benefit primary care include changes to the site-of-service differential, which benefited those practicing in independent offices; the expanded scope of the Advanced Primary Care Management (APCM) service codes benefited many primary care practitioners; and, although introduced in 2024, primary care is the top biller for G2211. G2211 is an add-on code that provides additional payment for the inherent complexity of certain office visits. Utilization of G2211 is expected to grow in the coming years.
The PFS is issued by the Centers for Medicare and Medicaid Services (CMS). CMS, like the rest of HHS, has been directed to prioritize Make America Healthy Again (MAHA) priorities. Improving primary care payment aligns with MAHA priorities for prevention and chronic care management.
#2: Alternative Systems Developed to Address Gaps Created by Government Policies
The Trump Administration’s policymaking approach was both dramatic and swift. Healthcare providers saw many longstanding systems dismantled or significantly altered in 2025. In response, practitioners and local and regional governments established alternatives to address information gaps or to propose alternatives to policy changes they believed were not grounded in scientific evidence.
Due to growing distrust of information from the Centers for Disease Control and Prevention (CDC) and significant disruptions to its publication of the Morbidity and Mortality Weekly Report (MMWR), the New England Journal of Medicine and the Center for Infectious Disease Research and Policy began publishing “public health alerts” that provided information similar to that typically published in the MMWR. The CDC has published the MMWR weekly since 1952, and it is considered an essential source of information for identifying and tracking emerging public health threats.
In light of changes at the federal level, several states and regional alliances have begun developing their own public health guidance. The HHS Secretary’s decision to fire every member of a panel that provides guidance to the CDC on vaccines and then appoint vaccine critics unsettled many public health advocates. California, Oregon, and Washington formed a collaborative to issue coordinated health and immunization guidelines. States in the Northeast formed a similar coalition. The National Network of Immunization Coalitions was formed to provide information on local, state, and national groups that can offer localized, evidence-based information.
Medical specialty societies such as the American Academy of Pediatrics, the American College of Obstetricians and Gynecologists, the American Medical Association (AMA), and the American Society of Clinical Oncology (ASCO) have begun issuing alternative vaccine guidance that diverges from the federal CDC guidelines.
These are just three examples of many in which the medical and scientific community has adjusted to changes in 2025. While these do provide support, they are patches, not replacements.
#3: CPT and RUC in the Crosshairs
The use of CPT codes in healthcare transactions is codified in statute, and historically, CMS has relied on the AMA RVS Update Committee (RUC) for data to establish the valuation of medical services. Over the years, the use of CPT codes and the RUC’s influence on rate-setting have been challenged, but objections to the role of CPT and the RUC seem especially heightened this year. In 2025, one senator waged a campaign focused on the millions in royalties the AMA collects annually from providers and insurers for the use of CPT codes in healthcare transactions, and CMS finalized policies in the 2026 Medicare PFS Final Rule that meaningfully reduced the RUC’s role in setting rates.
As chair of the Senate Committee on Health, Education, Labor, and Pensions (HELP), Senator Bill Cassidy (R-LA) launched an investigation into the AMA’s CPT royalty income and its impact on healthcare and patient costs. In 2025, he sent the AMA two letters (in October and December) demanding responses to a series of questions about the AMA’s current pricing and framework for accessing CPT codes. He also released a survey for providers, payors, and health IT companies regarding their CPT coding contracts.
In the CY 2026 PFS, CMS finalized policies that marked a shift away from its historic reliance on the RUC to set rates. CMS accepted most of the RUC’s work RVU recommendations, but at the same time implemented a 2.5% across-the-board reduction in work RVUs for time-based codes. CMS declined to use AMA’s Practice Information Survey for the fee schedule due to concerns about low response rates. CMS is also increasingly using Hospital Outpatient Prospective Payment System data for the PFS for radiation therapy beginning in 2026. Taken together, these actions narrow the RUC’s influence on the fee schedule.
The CPT/RUC processes have been important pathways for medical specialty societies and medical practitioners to provide input into code development and the valuation of the services they provide. Reducing the influence of the CPT/RUC processes without an alternative pathway could diminish the voice of medical professionals.
#4: AI is Everywhere, and the Feds Want to Be in Charge
You cannot talk about 2025 without discussing the explosion of artificial intelligence (AI) and the Trump Administration’s approach to AI policy.
During the Trump Administration, the federal government pursued an agenda focused on accelerating AI innovation and reducing regulatory burden. This approach sharply contrasts with the prior administration's focus on risk mitigation and guardrails. The Trump Administration’s approach was reflected in a series of executive orders, requests for information, and proposed rules that sought to reduce regulatory burden, expand the use of AI throughout the federal government, including HHS, and restrict AI policymaking to the federal level. There is concern that the combination of rapid uptake and limited regulation will shift the burden of ensuring the safety and efficacy of AI-enabled medical devices to users such as hospitals, medical practices, and individual physicians.
While Congress has failed to pass federal AI legislation, the Trump Administration has sought to stifle state-level regulation through its most recent executive order, which restricts state AI regulations. President Trump signed an executive order on December 11, 2025, to establish a uniform national AI policy and discourage a "patchwork" of state-level regulations. It establishes an AI Litigation Task Force to challenge state AI laws in court and creates a process to assess any conflicting state laws.
While generally viewed as having good relations with the leading AI firms, the administration has been resistant to certain stakeholder collaborations seeking to establish standards for the field. For example, CHAI is a private, nonprofit coalition of academic medical centers, technology companies (including Google and Microsoft), and healthcare organizations that aims to establish consensus standards and best practices for the use of AI in healthcare. It was formed in 2022 during the Biden administration. HHS officials have criticized CHAI's efforts to create an industry-led oversight framework, arguing that an organization founded in partnership with "Big Tech" has a conflict of interest and could stifle competition and innovation among health-tech startups.
The growth of AI in healthcare in 2025 is also reflected in the agendas for the CPT Editorial Panel (Panel) meetings. The agendas for the three 2025 meetings consistently included multiple code applications for AI-enabled medical services. To date, the Panel has approved 21 Category III AI-enabled codes, three Category I AI-enabled codes, and five Proprietary Laboratory Analyses (PLA) CPT codes. The Panel is considering revising its framework for assessing and categorizing AI-enabled CPT codes.
#5: Politics Entering Medical Practices
While politics and healthcare have always been intertwined, in 2025, politics entered medical practices in unique and real ways.
In 2025, the US government experienced the longest shutdown in history, lasting 43 days. This caused significant disruptions to medical practices, affecting their ability to provide patient care, pay employees, and manage their practices. The shutdown delayed Medicare payments, allowed telehealth rules to lapse, reduced support from federal agencies, and paused public health initiatives.
While major medical groups are at an impasse with the federal government over vaccine policies, physicians report rising vaccine hesitancy. Although vaccine skepticism has a long history and grew during the COVID-19 pandemic, practitioners are reporting increasingly tense and challenging conversations about vaccines during patient visits as the debate rages on in Washington, DC.
An executive order issued in January 2025 removed restrictions that had made hospitals off-limits to Immigration and Customs Enforcement (ICE) activities. The order permits ICE to conduct enforcement actions in healthcare settings, including hospitals and clinics. In 2025, hospitals and clinics began drafting guidelines and policies for responding to ICE. In doing so, they had to interpret federal rules and the nuances of state laws, and they must also comply with HIPAA.
2026 will bring its own twists and turns, but turning the calendar does not mean any of these issues have been resolved. They will just make 2026 even more interesting! So rest up this holiday week because I think 2026 will keep us plenty busy.
Wishing everyone a happy new year!
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For more information and questions, please contact:
Sheila Madhani, MA, MPH
Madhani Healthcare Consulting, LLC
Email: smadhani@madhani-health.com Tel: (202)679-2977